How EPA can improve identifying and reducing environmental health inequities

Advancing health equity through environmental health science and policy is a core mission of PRHE. Inequities in exposures to environmental contaminants are an important contributor to health inequities and can have a significant effect on the quality of life in at-risk communities. A potentially important step toward addressing inequities came with President Biden’s Executive Order “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government” (E.O. 13985), issued on January 20, 2021.

E.O. 13985 states “that the Federal Government should pursue a comprehensive approach to advancing equity for all, including people of color and others who have been historically underserved, marginalized, and adversely affected by persistent poverty and inequality.” To achieve this vision, substantial improvements to the policies and programs of the U.S. Environmental Protection Agency (EPA) are critical. EPA must expand and improve its approaches for assessing how environmental exposures, risks and health outcomes vary across communities. Equally important, EPA support for greater community participation in EPA’s programs, and not just the opportunity for public input, is critical to ensuring that EPA is advancing equity for all.

To better understand health inequities, EPA should conduct more comprehensive assessments to identify differences by race/ethnicity and socioeconomic status in exposures to environmental contaminants, risks resulting from those exposures, and health outcomes. One of EPA’s existing efforts to assess cumulative risk is the National Air Toxics Assessment (NATA), which presents estimates of toxic air pollutants in every community in the U.S. The 2014 NATA was instrumental in identifying communities in Louisiana’s “cancer alley,” most of which are Black and low-income, that have extremely high cancer risks from exposure to toxic air pollutants. Efforts to assess risks from current and ongoing exposures should be expanded to encompass more environmental contaminants and focus more on identifying inequities rather than simply assessing the entire population without comparing exposure/risk of groups within the population. Such assessments are necessary to understand and address systemic inequities, as they identify important disparities that have not been addressed by existing EPA policies. 

EPA’s main approach to assessing and visualizing baseline exposures, risk and health outcomes across different types of environmental contaminants is EJSCREEN, in which 11 environmental indicators (such as air toxics risk, particulate matter concentrations, and proximity to hazardous waste sites) are combined with demographic data. EPA can improve EJSCREEN by adopting the methods and tools of California’s CalEnviroScreen, which cumulatively assesses environmental exposures and factors that increase a population’s health vulnerabilities (e.g., educational attainment, housing burden, linguistic isolation, poverty). Creating a national “US-EnviroScreen” will enable EPA to better identify overburdened communities across the country. 

Next, EPA needs to determine whether its regulations are contributing to the goal of reducing health inequities. For each regulation to reduce exposures to harmful pollutants and chemicals, EPA should analyze the characteristics of the exposed population (e.g., race/ethnicity, socioeconomic status of those most-exposed), and determine whether the projected exposure reductions reduce disparities in exposure and risk. For situations where data are not available to assess the effects of a regulation on health inequities, EPA must develop and implement strategies to collect the necessary data.

For EPA to succeed in reducing health inequities, the Agency needs to implement structural changes in its scientific, regulatory and public engagement programs to recognize that community residents are experts on environmental conditions where they live. EPA’s current approach to risk assessment usually looks at a specific pollutant, or emissions from a single facility, rather than the real-world experience of community residents who are affected by multiple pollutants from multiple sources through multiple exposure pathways, along with interacting influences on risk, like poverty and stress.

To reduce inequities, EPA must engage with communities to understand numerous harmful exposures as well as the non-chemical factors that can make people even more susceptible to poor health outcomes due to chemical and pollution exposures. This new approach to community participation by EPA would include actively seeking out and engaging in discussions with representatives of underserved communities, providing resources to communities to support their interactions with EPA, providing community-specific explanations of EPA’s data and technical analysis, and involving these communities in developing recommendations for acceptable, practical, and culturally sensitive mitigation strategies. These structural changes in community participation need to be an essential element of the risk assessment process and the regulatory process in every EPA program.

Principles of environmental justice and community participation must be integrated into every aspect of EPA’s work. More details can be found in recommendations submitted by PRHE to the U.S. Office of Management and Budget, which is organizing the response to E.O. 13985 across the federal government.

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About the author

Daniel Axelrad worked at the U.S. Environmental Protection Agency for 33 years in the Office of Pollution Prevention and Toxics (1987-1993) and the Office of Policy (1993-2020). His areas of expertise include science policy, children’s environmental health, benefit-cost analysis and risk assessment. He has a bachelor’s degree in economics from Occidental College and a master’s in public policy from Harvard University.